Email Communication between Richard Keigwin, EPA Office of Pesticide Programs, and 

William Swietlik, EPA Office of Water 

From: Keigwin, Richard (Keigwin.Richard@epa.gov) 

Sent: Wednesday, April 30, 2014 6:51 AM 

To: Swietlik, William 

Cc: Kim Wagoner; Elizabeth Sabol; Kimberly Bartell; Goodwin, Janet; Brady, Donald; 

Dumas, Richard 

Subject: RE: Questions for OPP about Pesticides 

BillIn the attached, you should find our responses to the questions you posed as part of the 2014 

Annual Review of OW's industrial wastewater effluent limitations guidelines. Please let us 

know if you have any additional questions or if you need clarification regarding any of our 

responses. Rich Dumas is also available to assist. 

--Rick 

Rick Keigwin 

Director, Pesticide Re-evaluation Division Office of Pesticide Programs US Environmental 

Protection Agency 

From: Swietlik, William 

Sent: Thursday, April 17, 2014 2:12 PM 

To: Brady, Donald; Keigwin, Richard 

Cc: Kim Wagoner; Elizabeth Sabol; Kimberly Bartell; Goodwin, Janet 

Subject: RE: Questions for OPP about Pesticides 

Don/Rick: 

As I mentioned in an earlier e-mail to you, as part of the 2014 Annual Review of OW's industrial 

wastewater effluent limitations guidelines (ELGs), we have initiated a review of pesticide active 

ingredients measured by existing or new analytical methods that do not currently have effluent 

limits under the Pesticide Chemicals Manufacturing ELG, as established in 40 CFR Part 455 

back in 1993/1998. See: http://water.epa.gov/scitech/wastetech/guide/pesticides/ 

To complete our review, it would be helpful to get some information from you regarding the 

pesticides registration process and the manufacture of some pesticides we have identified as a 

potential concern from our review. 

Attached, is a list of questions for which we would like your answers. 

Please let me know if you have any questions about our request. 

Thanks, 

Bill 
_________________________________ 

William F. Swietlik 

US EPA, Office of Water 

Engineering and Analysis Division (4303T) 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

202-566-1129: phone 

202-566-1053: Fax 
1 

Responses from OPP – April 29, 2014

Background related to questions: 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is the law governing pesticide 

registration (license). It provides the authority to regulate the content and labeling of pesticide 

products, but not pesticide production nor production facilities. Production can be for 

distribution within the U.S. or solely for export. When produced for distribution, sale and use 

within the U.S., a pesticide registration is required. However, products manufactured solely for 

export do not require a U.S. registration. Consequently, the status of the registration may not be 

a good indicator for determining which chemicals might be discharged into American 

waterways. However, under FIFRA section 7, production at each manufacturing facility must be 

reported annually to the appropriate EPA Regional office regardless of where the chemical will 

be sold. 

Reregistration is complete. The 1988 amendments to FIFRA established the reregistration 

process. It was a one-time review of all pesticides registered prior to November 1984. In the 

mid-1980s, EPA promulgated through rule making, a new set of study guidelines. Because of 

the higher data standards, Congress selected the November 1984 cut-off assuming newer 

registrations met a higher standard than some older products. The law did not sunset any 

registration nor did it provide any new authority to regulate pesticides. 

Registration review was mandated by the Food Quality Protection Act (FQPA) of 1996. The law 

requires the Agency to review each registered pesticide at least every 15 years. It also required 

that OPP establish the program through rule making. The rule became effective on October 10, 

2006. As with reregistration, the law does not establish a sunset provision nor create new 

authority to regulate pesticides. It did set some higher safety standards, particularly for risks 

associated with children’s exposure to pesticides. 

Review of Pesticides Without Effluent Limits Covered by Existing Analytical Methods: 

Questions for OPP 

April 16, 2014 

 As part of the 2012 Annual Review of existing industrial wastewater effluent guidelines, 

the Office of Water (OW) reviewed analytical methods recently developed or revised by the 

Agency to facilitate its identification of pollutants for which there are no ELGs in industrial 

wastewater discharge. From its examination of the 2012 Method Update Rule during the 2012 

Annual Review, OW identified 30 pesticide active ingredients (PAIs) that are now measured by 

existing analytical methods, but do not currently have effluent limits under the Pesticide 

Chemicals Manufacturing ELGs, as established in Tables 2 and 3 in 40 CFR Part 455, Subpart 

A. 

 For the 2014 Annual Review, OW is investigating whether manufacturers in the U.S. are 

producing any of the 30 unregulated PAIs and whether these ingredients may be present in 

industrial wastewater discharges. OW completed a preliminary review of potential discharges of 

these pesticides and did not identify any discharges from pesticide chemicals manufacturing 
2 

facilities reported to either discharge monitoring report (DMR) data or the Toxics Release 

Inventory (TRI) in 2011. Additionally, OW reviewed the pesticide registration status for each of 

these pesticides. It is understood that OPP requires registration for use and production of specific 

pesticide chemicals in the U.S. and is currently in the process of re-registering any pesticide 

originally registered before 1984. OPP prohibits use or production of any pesticide that is not 

currently registered or registered prior to 1984. Any pesticide registered after 1984 maintains its 

registration. 

OW has following questions for OPP regarding the pesticides registration process: 

1. Did we accurately characterize the registration process in the paragraph above? See 

background above.

2. How long does chemical registration last? Generally, there is no expiration date on a 

pesticide registered under section 3 of FIFRA. 

3. Will the registration for PAIs registered after 1984 expire? No. If yes, when? 

4. For chemicals that were registered prior to 1984, but are not currently going through 

re-registration, are they considered unregistered at this point? All currently registered 

pesticides will be re-evaluated through the registration review program. As discussed in 

response to Question 2, pesticide registrations generally do not expire, unless that is a 

condition of that specific registration. However, a number of products evaluated through 

the reregistration program have been canceled. U.S. production of these products, 

however, is permissible for export purposes only. 

5. What authority does the re-registration process have? (i.e., is it just a review? Can 

registration be revoked based on the review?) As discussed above, reregistration has 

been completed. All registered pesticides are now being re-evaluated through the 

registration review program. Through this program, OPP will determine if these 

pesticides continue to meet pesticide safety standards. If they do not, the Agency has the 

authority to impose limitations and/or restrictions on use, including cancellation if 

necessary. In addition, FIFRA does provide the authority to suspend if a registrant does 

not provide required data in a specified time frame. 

The 30 PAIs identified during the 2012 Annual Review are listed below in Table 1. The 

registration status for each PAI has been reviewed and notes are included in the table. We have 

the following additional questions for OPP about the PAIs listed in Table 1: 

1. What are the reasons for not re-registering some of the pesticides that were registered 

prior to 1984? The most common reason is that the company made a business decision 

to request a voluntarily cancellation of their registration rather than generating required 

data. In some cases, OPP identified an unacceptable risk and worked with companies to 

voluntarily cancel the registration.

2. Does OPP have plans to re-register any of the pesticides on this list that fall into the 

category described above in question 1? As discussed above, OPP is currently reevaluating the safety of all registered pesticides. Most of the pesticides listed in the table 

are not currently registered and, therefore, would not be reviewed through the 

registration review program. If a registrant were to seek registration for an unregistered 

active ingredient, the registrant must apply for a registration and submit currently all 

required data for the Agency’s consideration. 
3 

3. Does OPP have plans to register any of the pesticides on this list that were never 

registered? At this time, we know of no pending registration applications involving the 

non-registered chemicals on your list. 

4. Based on the list of pesticides, are there any that OPP would give a higher 

prioritization for further review over others? In developing our schedule for 

registration review, we did place priority on certain groups of registered chemicals, such 

as the organophosphate (e.g., chlorpyrifos-methyl, coumaphos, and ethoprop) and nmethyl carbamate (e.g., oxamyl) insecticides. For the chemicals not registered, many are 

organochlorines, which tend to be very toxic and persistent in the environment.

5. Does OPP have any additional data that would help us determine whether the PAIs 

may be present in industrial wastewater discharges from pesticide manufacturing in 

particular (or whether or not they are present in any industrial wastewater 

discharges)? Production data provided under section 7 of FIFRA might be useful. It 

does include production for export. We should note that these data are considered 

confidential business information under FIFRA. Only those with a FIFRA security 

clearance can access this information. OECA’s contact is Michelle Stevenson at 202-

564-4203. If needed, we can help direct you to people within OPP who also know the 

data.

6. Are there available data that document if these pesticide chemicals are currently being 

manufactured or used in the U.S.? In addition to the section 7 liaison mentioned above, 

OECA has been working on mapping the location of facilities using section 7 and other 

information. OECA’s contact is Melissa Saddler at 202-564-5455.

7. Can OPP point us to any additional data sources (e.g., literature, wastewater sampling 

data, manufacturing information) that may be useful for our review? We have already 

closely reviewed DMR and TRI data. None, other than section 7 data.

8. For trichloronate specifically, this pesticide chemical is not currently listed in the 

pesticide registration database. What is the status of this chemical? This insecticide is 

not registered in the U.S. nor Canada. 

Below is an updated table reflecting some clarifications and additional information. Note 

that for older chemicals, OPPIN often does not have accurate information on the first 

registration dates. If the chemical was subject to reregistration, the Reregistration 

Eligibility Decision (RED) document provides the most accurate information. 

Table 1. PAIs Registration Status 

EPA Method Chemical CAS Number Registration Status 

608.1 Chlorobenzilate 510156 All U.S. registrations have been canceled. 

Chloropropylate 5836402 All U.S. registrations have been canceled. 

Dibromochloropropane 96128 Never registered in the U.S.

Etridiazole 2593159 First registered in 1962; currently under 

registration review

614.1 EPN 2104645 All U.S. registrations have been canceled. 

615 Dalapon 75990 All U.S. registrations have been canceled. 

617 Carbophenothion 786196 All U.S. registrations have been canceled. 
4 

Table 1. PAIs Registration Status 

EPA Method Chemical CAS Number Registration Status 

Endosulfan sulfate 1031078 Never registered in the U.S. 

Endrin aldehydea 7421934 

Never registered in the U.S. All U.S. 

registrations of the parent compound, 

Endrin, have been canceled.

Heptachlor epoxideb 1024573 

Never registered in the U.S. All U.S. 

registrations of the parent compound, 

Heptachlor, have been canceled. 

Isodrin 465736 Never registered in the U.S. 

Strobane 8001501 All U.S. registrations have been canceled. 

619 Atraton 1610179 Never registered in the U.S. 

Secbumeton 26259450 Never registered in the U.S. 

Simetryn 1014706 Never registered in the U.S. 

622 Chlorpyrifos methyl 5598130 First registered in 1985; currently under 

registration review 

Coumaphos 56724 First registered in 1958; currently under 

registration review 

Ethoprop 13194484 First registered in 1967; currently under 

registration review 

Ronnel 299843 All U.S. registrations have been canceled.

Tokuthion 34643464 Never registered in the U.S. 

Trichloronate 327980 Never registered in the U.S. 

622.1 Aspon 3244904 All U.S. registrations have been canceled. 

Dichlofenthion 97176 All U.S. registrations have been canceled. 

Famphur 52857 All U.S. registrations have been canceled. 

Fenitrothion 122145 

First registered in 1975; currently under 

registration review. Only product registered 

in the U.S. is for formulating other 

insecticides. No end-use products registered 

in the U.S.

Fonofos 944229 All U.S. registrations have been canceled. 

Thionazin 297972 All U.S. registrations have been canceled. 

632 Fluometuron 2164172 First registered in 1974; currently under 

registration review

Neburon 555373 All U.S. registrations have been canceled. 

Oxamyl 23135220 First registered in 1974; currently under 

registration review

Source: Registration status information obtained from the Office of Pesticide Programs at 

http://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:1. a Endrin aldehyde has never been a registered pesticide, but is an impurity and breakdown product of a previously 

registered pesticide, endrin. Endrin is also a regulated PAI under the Pesticide Chemicals Manufacturing, 

Formulating, and Packaging ELGs (40 CFR Part 455).

b Heptachlor epoxide has never been a registered pesticide, but is a metabolite of a previously registered pesticide, 

heptachlor. Heptachlor is also a regulated PAI under the Pesticide Chemicals Manufacturing, Formulating, and 

Packaging ELGs (40 CFR Part 455). 

 
5